By Carol Tello and Giovanna Sparagna
On August 10, 2010, President Obama signed into law the Education Jobs and Medicaid Assistance Act, P.L. 111-226, which provides funds to the states for teachers' salaries and Medicaid costs. To fund this bill, Congress enacted all but one of the international...

[Editor's Note: This narrative is derived from Rhoades & Langer, U.S. International Taxation and Tax Treaties, § 12.02[3][a][ii][B] (Matthew Bender).]
The foreign tax credit is the international taxpayer's chief defense against double taxation of the same items of income, once by...